Privacy Policy

Who are we?

‘We’, ‘us’ and ‘our’ refer to International Mortgage Group Pty Ltd Trading as Simply Home Loans (ACN 120 337 420, Australian Credit Licence 394647) and our related corporate entities, authorised representatives, and credit representatives.

Your information and privacy

At our company, safeguarding your personal information is a top priority. This privacy policy outlines our commitment to handling the personal information we collect from you and how we use it. We understand the importance of only using your personal information for the purposes it was collected or as permitted by applicable laws. We want to assure you that your personal information will be treated with the utmost care and security to protect your privacy.

Our company is dedicated to complying with the Australian Privacy Principles for the safeguarding of personal information, as outlined in the Privacy Act 1988 and other applicable laws. We are committed to upholding these principles and ensuring that your personal information is kept secure and confidential at all time.

Personal information

Our definition of personal information pertains to information that can be reasonably used to identify you. This information may consist of details or opinions about you, and may include credit information as well. This privacy policy pertains to an application that you make to a mortgage manager for a loan, which could be consumer credit or commercial credit, or if you have offered to guarantee the applicant’s loan obligations. This policy also includes your consent to disclose certain information to other relevant organizations, as described below.

The personal information we may collect about you includes your name, date of birth, address, account details, occupation, and any other details required to identify you. Credit information or credit eligibility information that we collect is used to determine your eligibility for finance and may include any outstanding finance you may have, repayment history, and any defaults. This information is typically shared between credit and finance providers and credit reporting bodies.

Registration information pertains to details you provide during the registration process for a service, such as creating an account, subscribing, or entering a competition. Registration information may include your name, email address, address details, gender, and date of birth, along with any additional details you provide during the relationship.

If you are applying for finance, we may also collect details such as the ages and number of your dependents and cohabitants, the length of time at your current address, your employment details, and proof of earnings and expenses.

Why do we collect your personal information?

We gather personal information to fulfill the services you have requested, manage our relationship with you, and evaluate your finance application as well as handle that finance. We may also collect your personal information for direct marketing purposes and to maintain our relationship with you. Additionally, we may offer you other products and services at times.

To maintain a successful business relationship with you, we may share your personal information with other organizations that offer products or services marketed or used by us. Furthermore, we may disclose your personal information to any other organization that has an interest in your finance or our business.

We collect your personal information directly from you wherever feasible and reasonable. We may also obtain your personal information from credit and authorized representatives of our license(s), as well as other individuals such as accountants and lawyers. Additionally, we collect information from your application and the records we keep about the products or services you receive from us. Occasionally, a Lenders Mortgage Insurance (LMI) (Insurer) may gather additional personal information about you during the LMI coverage provided to the lender for your loan. The terms of this notice and the LMI insurer’s Privacy Policy will apply to the collection, use, and disclosure of that information.

How information is collected from other sources

We may collect information about you from other sources as permitted by the Privacy Act 1988. However, we will only do so when it is reasonably necessary, for instance, when:

  • we need to obtain information (including commercial credit information such as your credit history or creditworthiness, consumer information, and information on overdue payments) from a credit reporting body for any of the purposes mentioned below.
  • we obtain information about your loan or guarantee from any of the organizations described above;
  • we are unable to contact you and have to rely on publicly available information to update your contact details;
  • we conduct property checks through public registers or our service providers on the property you offer as security;
  • we exchange information with your legal or financial advisers or other representatives.

When the law requires the collection of information

Organisations are subject to laws that may require us to collect personal information about you. For instance, we may need information about you to verify your identity in compliance with the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act).

We may use your personal information for various purposes, which may include but are not limited to:

  • Providing you with information about loan products or related services;
  • Determining your eligibility for a loan or any related service that you have requested;
  • Processing your loan application and providing you with a loan or related service;
  • Administering your loan or any related service, such as addressing requests or handling complaints;
  • Confirming your identity;
  • Informing you about other products or services offered by us or our affiliated companies that may be of interest to you, unless you opt out;
  • Enabling us to run our business efficiently and perform administrative and operational tasks;
  • Preventing or investigating any fraudulent activities or crimes, or suspected fraudulent activities or crimes;
  • Complying with legal, regulatory, or binding codes of conduct; and
  • Any other purpose that you have consented to. You have the right to inform us at any time if you do not wish to receive direct marketing offers from us, and we will act on your request as soon as possible.

Credit information about you may also be used for the following purposes:

  • Assisting an insurer to evaluate the risk associated with providing insurance to the lender or addressing the lender’s relationship with the insurer;
  • Assessing the lender’s decision to accept a guarantor or the risk associated with a guarantor being unable to meet their obligations;
  • Considering requests for financial hardship; and
  • Assessing whether to securitise loans and to arrange for the securitisation of loans that the lender provides.

Information about you may be used by an LMI insurer for various purposes, including:

  • determining whether to provide insurance coverage to a lender under an LMI policy;
  • assessing the risk of you or a guarantor defaulting on your obligations to a lender;
  • administering and modifying the insurance cover, including for securitization and hardship applications;
  • verifying information that the LMI insurer collects about you;
  • handling claims and recovering proceeds, including enforcing a loan or a guarantee in place of a lender if the LMI insurer pays out an insurance claim on your loan or the loan you guarantee;
  • conducting risk assessment and management involving credit scoring, portfolio analysis, reporting, and fraud prevention;
  • complying with legislative and regulatory requirements, including requirements under the Privacy Act 1988 and Insurance Contracts Act 1984, as amended from time to time;
  • for a mortgage insurance purpose relating to you; and
  • for any other purpose under the insurance policy that the LMI insurer issues to the lender relating to your loan.

Information about you may be used by the title insurer or its related entities for the following purposes:

  • To assess the risk of providing title insurance to the lender; • For subsequent administration or variation of the title insurance policy;
  • For risk assessment, reporting, fraud prevention, enforcement, and claim recovery activities; • To discharge your existing mortgage over the security property and register your new mortgage over the security property where a refinance is taking place;
  • To handle claims and to enforce a loan or a guarantee in place of a lender if the title insurer pays out an insurance claim on your loan or the loan you guarantee;
  • For a title insurance purpose relating to you;
  • To comply with legislative and regulatory requirements; and
  • For any other purpose under the contract between a lender and the title insurer.

We may share your personal information with the following parties:

  • Prospective funders/lenders or intermediaries involved in your finance requirements;
  • Mortgage manager listed in the Schedule of Related Parties;
  • Loan servicer listed in the Schedule of Related Parties that considers the application or administers your loan for the lender;
  • LMI insurer (‘Insurers’) listed in the Schedule of Related Parties that considers a lender’s request for LMI cover or that gives LMI cover to the lender for your loan;
  • Title insurer (‘Insurers’) listed in the Schedule of Related Parties that considers a lender’s request for title insurance cover or that gives title insurance cover to the lender for your loan, and its related entity;
  • Other related and unrelated organizations that manage or administer your finance such as third-party suppliers, printing and postal services, and call centers;
  • Associated businesses that may want to market products to you;
  • Companies that provide information and infrastructure systems to us;
  • Anyone who represents you, such as finance brokers, financial planners, lawyers, and accountants;
  • Anyone with your consent;
  • Where required by law, such as under the AML/CTF Act;
  • Investors, agents or advisers, or any entity that has an interest in our business;
  • Credit reporting bodies;
  • Organizations involved in debt collection or purchasing debts;
  • Organizations, such as fraud reporting agencies, that identify, investigate and/or prevent fraud, suspected fraud, crimes, suspected crimes, or other serious misconduct;
  • Organizations involved in surveying or registering a security property or which otherwise have an interest in a security property;
  • Government or regulatory bodies as required or authorized by law. In some instances, these bodies may share the information with relevant foreign authorities;
  • Rating agencies to allow the rating agency to rate particular investments;
  • Organizations involved in securitizing your loan, including re-insurers and underwriters, loan servicers, trust managers, trustees, and security trustees;
  • Guarantors and prospective guarantors of your loan;
  • Borrowers or prospective borrowers of the loan you guarantee;
  • Payment system operators to allow us to investigate or correct payments on your loan;
  • Your employer, referees, or identity verification services; and/or

Before sharing your personal information with another party, we will ensure that:

  1. The person or organization has a commitment to protecting your personal information that is at least equivalent to our own, or
  2. You have given us permission to share the information.

We may use your personal information to send you current information about finance, offers, changes to our organization, or new products or services offered by us or our associated companies. If you do not want to receive marketing information, you may decline it at any time by contacting us at inbox@simplyhomeloans.com.au. If the marketing is via email, you may use the unsubscribe function to opt-out. We will not charge you for your request, and we will promptly meet it in the most reasonable manner.

We value the accuracy and currency of the personal information we have about you. To ensure that we have the most up-to-date information, we may request that you inform us if any of your personal details have changed during our association. If you need to update your personal information, please contact us. We trust that you will assist us in ensuring that the information we have about you is accurate and complete.

We understand the importance of accurate and up-to-date personal information, and we are committed to providing you access to your personal information upon request. You may ask us to provide you with access to any of the personal information we hold at any time. We reserve the right to charge a fee for the costs of retrieving and supplying the information to you.

We will respond to your request as soon as possible and no later than seven days after we receive it. In some cases, we may need to contact other entities to properly investigate your request. However, there may be situations where we are not required to provide you access to your personal information, such as if the information relates to existing or anticipated legal proceedings or if your request is vexatious.

If you find any incorrect, inaccurate, or outdated information in your personal information, you may request us to correct it. We will try our best to make the correction at the time of the request. If we cannot make the correction immediately, we will respond to your request within seven days and provide details about whether we have corrected the personal information within 30 days after our investigation. We may need to consult with other entities during our investigation. If we cannot correct the personal information, we will explain the reasons for our refusal.

If we collect government identifiers, such as your tax file number, we will only use or disclose this information as required by law. We will not use a government identifier to identify you.

 

Complaints

If you are not satisfied with how we have handled your personal information, or if you have a complaint regarding our compliance with the Privacy Act 1988, you can contact our Complaints Manager at inbox@simplyhomeloans.com.au. We will acknowledge your complaint within one business day and provide a decision within 30 calendar days.

If you remain unsatisfied with the response from our Complaints Manager, you may escalate your complaint to the Privacy Commissioner. You can contact them through the Office of the Australian Information Commissioner website (www.oaic.gov.au) or by calling 1300 363 992.

For more information about how we handle your personal information, you may contact us. We regularly review our policies to stay up-to-date with market expectations, changing technology, and legal and industry practices. As a result, we may change this privacy policy as needed. If you require this policy in an alternative format, please let us know. This Privacy Policy came into effect on May 1st, 2023